Security Information

At ProGrowth, we know how important personal
privacy is to you. Because of our interest in protecting your
privacy, our combined banks and companies - all affiliates of
ProGrowth -- have adopted the following privacy principles,
continuing our commitment to you, our valued customer:

Recognition of Your
Expectation of Privacy

We recognize that you expect privacy and security
for your personal and financial affairs. We understand the need to
safeguard our sensitive information about you that you have
entrusted to us within our affiliated family of banks and companies.
We maintain standards and procedures designed to prevent misuse of
this information.

Our Collection,
Retention, and Use of Information about You

We collect, retain, and use information about you
only where we reasonably believe that it will help administer our
business or provide products, services, and other opportunities to
you. We collect and retain information about you only for specific
business purposes - and we will tell you why we are collecting and
retaining it upon your request. We use information to protect and
administer your records, accounts, and funds; to comply with certain
laws and regulations; to help us design or improve our products and
services; and to understand your financial needs so that we can
provide you with quality products and superior service.

Our Maintenance of
Accurate Information

We have procedures to help assure that your
financial information is accurate, current, and complete in
accordance with commercial standards. We also have procedures to
respond to your requests to correct inaccurate information in a
timely manner. While some of these procedures are required by
federal or state law, we have implemented additional procedures to
maintain accurate, current, and complete financial information,
including processes to update information and remove old
information.

Limiting Employee Access
to Information

We have procedures that limit employee access to
personally identifiable information to those employees with a
business reason to know such information about you. We educate our
employees about the importance of confidentiality and customer
privacy through standard operating procedures, special training
programs, and our policies on ethics. We take appropriate
disciplinary measures to enforce employee privacy responsibilities.

Security Procedures to
Protect Information

We maintain security standards and procedures to
help prevent unauthorized access to confidential information about
you. We update and test our technology to improve the protection of
our information about you and to assure the integrity of our
information.

Restrictions on
Disclosing Information to Parties Outside of Our Affiliated Banks
and Companies

We do not reveal specific information about your
accounts or other personally identifiable data to parties outside
our affiliated banks and companies for their independent use unless:

you request or authorize it;

the information is provided to help complete a
transaction initiated by you;

we are legally required to do so (e.g. in
response to a subpoena or fraud investigation)

you request or consent to disclosure

you have been informed about the possibility of
sharing information for marketing or other similar purposes
through a prior communication and you have been given the
opportunity to decline

we have agreed to provide information to a
reputable credit bureau or similar information reporting agency;
or
the disclosure otherwise is lawfully permitted or required.

Maintaining Your Privacy in Business
Relationships with Parties Outside of Our Affiliated Banks and
Companies

Sometimes it is necessary to provide personally
identifiable information about you to a party outside our affiliated
banks and companies, such as to a vendor or service company that we
hire to prepare your account statements or to provide support or
services for one or more of our products. These vendors and service
companies agree to safeguard our confidential information about you
and your products and services with us and must abide by applicable
laws.

Disclosing Our Privacy
Commitment to You

We want you to understand our commitment to
personal privacy and our use of information. For this reason, we
have prepared these Privacy Principles. These materials will answer
most of the important questions that you may have about how we
gather, protect, and use information.

These Privacy Principles apply to individuals,
and we reserve the right to change them, along with related
provisions, at any time.